Challenges for Psychologist Regulatory Boards in the 21st Century

By Wil Counts R.Ph.,Ph.D.
November 1, 2000 - Last updated: May 31, 2011

Change is inevitable in a progressive society. Change is constant. -Benjamin Disraeli

Here we are entering the 21st Century with telehealth, the potential for internet therapy, and countless technological advances prompting changes in the manner in which psychology is practiced, while the regulation of psychology is in many cases still operating in the 20th Century. Society is becoming more and more mobile directly and via the internet. As technology shrinks our world, current state boundaries become increasingly irrelevant. State and provincial regulatory boards will have to adapt to the reality of continental and global delivery of psychological services.

Momentum toward mobility is building. With the efforts of credentialing associations like the ASPPB, state licensing boards now have options to facilitate re-licensure and mobility. The Association of State and Provincial Psychology Boards (ASPPB) which is comprised of 62 licensing boards/agencies in the United States and Canada has developed two reciprocity-oriented programs. Both of these have the potential to resolve the issues of interstate practice and mobility for psychologists.

One path to mobility is the Reciprocity Agreement. This requires participating states and provinces to bring their licensing requirements into conformity with the standards in the Reciprocity Agreement and to accept each others’ licensees. Currently, ten states and provinces have joined the ASPPB reciprocity agreement.

Another option is the Certificate of Professional Qualification in Psychology (CPQ). This facilitates mobility by recognizing a licensed psychologist meeting specific CPQ standards. This certificate of endorsement facilitates re-licensure in other jurisdictions.

There are also provisions in many states and provinces to waive certain requirements based upon possessing an ABPP diploma, listing in the National or Canadian Registers of Health Care Providers in Psychology, and a grandparenting provision for psychologists trained years ago.

Of the mobility options mentioned, the CPQ is being considered by and accepted by an increasing number of state boards and is an appropriate option to overcome differences in licensure requirements. The CPQ documents that individuals holding the certificate has met specific requirements relative to his or her educational background, supervised experience, and performance on the Examination for Professional Practice in Psychology (EPPP), and has been licensed and practicing for at least five years without disciplinary action. The CPQ can then be accepted by participating psychology licensing boards to streamline the application and licensure process. With the CPQ, it does not matter if the individual licensee is missing a specific course or unique requirement. A minimum of five years experience without being disciplined is a measure of proven competence to practice psychology safely, provided the licensee has met all other requirements in the state issuing the license and meets the specific requirements for the CPQ.

Twelve states and provinces currently accept the CPQ for licensure mobility and eleven more are in the process of making changes in their law and rules, which would allow them to accept the CPQ. Those currently accepting the CPQ are Alberta, California, District of Columbia, Kentucky, Mississippi, Nevada, Oklahoma, Ohio, Ontario, Pennsylvania, Vermont, and Wisconsin. Jurisdictions making changes to accept the CPQ are Alabama, Arizona, Connecticut, Louisiana, New Mexico, Manitoba, Missouri, Michigan, Nova Scotia, Rhode Island and Wyoming. However, approximately forty jurisdictions between the United States and Canada have not adopted the CPQ or any other mobility provision. Perhaps out of sight is out of mind for some who focus primarily on local regulatory issues.

The Canadian Government recently developed the Agreement on Internal Trade which essentially states that if a healthcare professional is licensed to practice in one jurisdiction, he/she must be able to practice in any other jurisdiction in Canada. The Canadian licensing boards are now struggling to implement this federal legislation by making the necessary changes to eliminate barriers to mobility of qualified professionals.

Our federal government is actively exploring mobility and the regulation of telehealth. In a 1998 report of recommendations for regulation of the Healthcare workforce from the Pew Health Professions Commission, one of the recommendations was that Congress should enact legislation that facilitates professional mobility and practice across state boundaries.

More recently, the Telehealth Improvement Act of 1999 has introduced legislation and if passed could have an impact on state licensure and mobility. This Act states: “If, with respect to a report submitted, the Secretary of Health and Human Services determines that States are not making progress in facilitating the provision of telehealth services across state lines by eliminating unnecessary requirements, adopting reciprocal licensing arrangements for telehealth services, implementing uniform requirements for telehealth licensure, or other means, the Secretary shall include in the report recommendations concerning the scope and nature of federal actions required to reduce licensure as a barrier to the interstate provision of telehealth services.

Certainly, mobility can be seen as a precursor to telehealth practice. If a licensed psychologist has an endorsement such as the CPQ, which documents that the individual holding the certificate is competent for independent practice, and all jurisdictions accepted the CPQ, the psychologist in essence could be credentialed to practice in each jurisdiction in person, or via telehealth.

If regulation of the profession is a key responsibility of state and provincial licensure boards, then why are so many regulatory boards reluctant to adopt mobility provisions with such convincing rationale from both licensees as well respected leaders within and outside the profession?

Some states are concerned that reciprocity could result in an influx of psychologists relocating to their state. Some licensees who are struggling financially are concerned about competition. And, of course, virtually each jurisdiction feels that they know what is necessary for independent practice in their jurisdiction, which has resulted in unique requirements setting them apart from other jurisdictions. Others are reluctant to take on the arduous task of going before state legislatures to seek changes in licensure law, which would allow for acceptance of others states’ licensees in a reciprocal fashion.

Another pressing issue is the lack of uniformity of credentialing standards from jurisdiction to jurisdiction. With the large amount of variance in doctoral training programs and licensing requirements across jurisdictions, it can be extremely difficult to impossible for most psychologists to become relicensed in other jurisdictions.

Perhaps the licensees/practitioners need to become more aware of the forces supporting as well as the forces blocking mobility and become active in the political process by contacting their board members, state association leaders, and legislatures, urging them to support appropriate avenues toward mobility in your jurisdiction.

Now is time for state boards to give thoughtful consideration and to take positive action toward unifying licensure requirements and adopting provisions for mobility of qualified licensed psychologists. Furthermore, if state boards refuse to act proactively, they could find themselves left out of the decision-making process and in a similar position to that of the Canadian provinces where the Federal government made the decision for intrastate licensure.

In embracing change, entrepreneurs ensure social and economic stability. -George Gilder

Wil Counts is a licensed psychologist and a registered pharmacist. He has served on the State of Arizona Board of Psychologist Examiners for the last twelve years and is currently a member of the Long Range Resource Planning Committee for the Association of State and Provincial Psychology Boards. Dr. Counts is also a founding member of the Academy of Medical Psychology whose mission is to facilitate accountability in the provision of essential services in medical psychology for the purpose of promoting standards of practice in order to benefit the public. He is an instructor of Psychology at GateWay Community College, is in private practice and can be reached via e-mail at

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